While Delhi ramps up action to control deadly smog and also shows results, air pollution spirals out of control in other cities to become a national crisis

January 03, 2018

While in 2007 60per cent of cities monitored had PM10 levels officially classified as critical in this has increased to 88per cent in 2016. Cities with good air quality (50% per cent below the standards) have reduced from 13per cent in 2007 to 2per cent in 2016.

Air quality monitoring is very limited across India. Only 303 cities out of 6,166 Census cities towns are monitored – only 5 per cent of cities and town.

Only 57 cities have continuous real time monitoring stations. Rest are manual that does not allow daily relay of real time air quality for immediate action.

Multi pollutant crisis is growing. While nitrogen oxide levels exceeded annual average standards in 17per cent of cities in 2007 it has increased to 29per cent in 2016. In 2007 not a single city had critical NOX levels; but in 2016 12per cent cities are in critical category.

New State level Global Burden of Disease in India shows air pollution has moved up in rank in nearly all states of India and the diseases directly affected by air pollution like ischemic heart disease and chronic respiratory ailments are among the top killers.

Smaller cities are more polluted. Out of these 46 million plus cities (whose data is reported in the Parliament), the most polluted cities are Allahabad, Varanasi and Lucknow which was followed by Delhi, Ghaziabad, Agra, Dhanbad, Jaipur, Kanpur and Amritsar.

Supreme Court direction on notification of comprehensive action plan opens up opportunity for more systemic changes for sustained air quality gains. Other cities need to adopt this template.

New Delhi December 27, 2017: Centre for Science and Environment releases its new national air quality analysis that shows how air pollution is spiraling out of control across the country with serious public health consequences. Delhi which is fighting a tough air pollution battle and has begun to ramp up action has started to control pollution peak as evident from less number of severe and emergency days this winter. While graded response action plan has contributed to this trend, urgent implementation of the comprehensive action plan as directed by the Supreme Court is needed to sustain the gains.

National action is needed now to ensure all cities adopt time bound action plan to meet clean air targets and address the national health crisis.

Air pollution is a national crisis

Majority cities in grip of critical particulate pollution: The Central Pollution Control Board (CPCB) submits annual average concentration for pollutants for 46 cities (out of which data is available for 44 cities) with million plus population to Rajya Sabha. This data is available from 2007 to 2016. CPCB classifies annual average pollution levels in terms of low (50% less than the standard), moderate (meeting the standards), high (1.5 times the standards) and critical (more than 1.5 times the standards), Accordingly, the share of cities in critical category has increased from 60 per cent in 2007 to 88 per cent in 2016. It is however evident that out of 255 cities nearly 78 percent cities exceeded the standard in 2016.

Share of cities with good annual air quality years have reduced drastically: There is a drastic fall in the number of cities with particulate levels below the standard. This has reduced from 13per cent in 2007 to 2 per cent in 2016. There are no cities which are in low category (50% below the standard) now.

Multi pollutant crisis is growing: Along with particulate matter gaseous pollution has also started to increase in several cities. The number of cities with nitrogen dioxide levels exceeding the annual average standards has increased from 17per cent in 2007 to 29per cent in 2016. In 2007 not a single city had critical PM10 levels (or with levels more than 1.5 times the standard); in 2016 critically polluted cities account for 12per cent of the cities. Nitrogen oxide is very toxic and also contributes to formation of very harmful ozone. Cities with high NO2 levels are Amritsar, Aurangabad, Delhi, Faridabad, Jaipur, Kolkata, Meerut, Navi Mumbai, PimpriChinchwad, Pune, Thane, and Vijaywada.

Regional differences in pollution levels influenced by climate and meteorology: There are strong regional differences in pollution concentration. Therefore, it is often not possible to compare pollution levels of cities from different regions. As northern India is land locked pollution build up in northern Indian cities is always much higher compared to other regions. In coastal cities of South or West strong sea breeze lower concentration. CSE has compared cities separately for different regions with the regional average and the standards. Indo Gangetic plain has the highest pollution levels which is followed by Hot & Dry (North). But all the regions have PM10 levels above the annual standard since 2007.

Cities with mixed air quality trends: In 28 cities there is mixed trend in particulate level over time - PM10 levels have reduced to increase once again. These include Delhi, Chennai, Hyderabad, and Bengaluru and smaller cities like Surat, Pune, and Thane etc. Pollution levels have seen intermittent stabilisation. This shows that action has to gather speed to sustain air quality gains.

Cities with stable but high trends: In 6 cities the trend though high has stabilized over time. These cities include Mumbai, Nagpur, Ahmedabad, Faridabad, Kanpur, and Jodhpur. These cities need to ramp up action to reduce pollution levels and meet clean air standards throughout the year.

Cities with declining trend: In 10 cities the PM10 levels show declining trend but this will have to be understood with riders. This is a reflection of changes in location of monitoring stations and also the monitors that are being used for reporting data. These cities include Amritsar, Coimbatore, Gwalior, Howrah, Indore, Jabalpur, Kolkata, Ludhiana, Raipur and Vishakhapatnam.

Smaller cities are more polluted: Out of 46 million plus cities (whose data is reported in the Parliament), the most polluted cities are Allahabad, Varanasi and Lucknow which was followed by Delhi, Ghaziabad, Agra, Dhanbad, Jaipur, Kanpur and Amritsar.

Majority of urban Indians live in cities with critical and high pollution levels: Close to 40 per cent of urban population lives in 44 cities with more than a million population. The highest PM10 levels have been found in cities with population greater than 10 million. This makes urban population extremely vulnerable to pollution and illness.

Poor air quality monitoring capacity in India: Limited air quality monitoring across India limits our knowledge of state of air in most of our cities and towns. Only 303 cities out of 6,166 Census cities towns are monitored – this is a mere 5 per cent. Only 57 cities have continuous real time monitoring stations. The rest are manual which does not allow daily reporting of real time air quality data and smog alter for action and public health protection.

Delhi has the highest number of monitoring stations – more than 30. Earlier there were 11 real time air quality monitoring stations and after the court directives, DPCC has set up 21 more air quality monitoring stations. Under the Supreme Court directive air quality monitoring network is also being expanded in the NCR towns.

Even mega cities like Kolkata and Mumbai have limited monitoring in terms of continuous ambient air quality monitoring stations. Kolkata has only two whereas as Mumbai has only three.

Daily reporting of air quality data and index inadequate in cities: To make air pollution monitoring relevant to public health daily reporting based on national air quality index (that classifies air quality based on severity of pollution) is essential. CPCB has setup a data communication protocol which requires data transfer from SPCB operated realtime monitoring stations at 15 minutes frequency to central servers, which further has system to estimate AQI for monitoring location. This gets displayed in CPCB web portal.

CSE analysis of the daily reporting of AQI shows found that as many as 22 cities do not have complete data and AQI values are missing for more than 10 per cent of days in a month. This compromises the effectiveness of the AQI system and daily reporting. In cities of Dewas, Howrah, Ujjain as much as 80 per cent of daily AQI values are missing.

During the month of November 26 cities had AQI in very poor and severe category and the maximum being of Jodhpur and Durgapur. Five cities had AQI in good category. Vishakhapatnam had the maximum number of good days i.e. 20 per cent.

Unacceptable health costsIndia is paying a very high price for its polluted air and the landmark studies shows air pollution to be the second largest killer in the country. Several global and national studies have already proven severe health risks from air pollution. Global burden of disease (GBD) February 2017 shows that of more than total global 4.2 million early deaths -- 1.1 million deaths occur in India alone. This is more than a quarter of the global deaths. While early deaths related to PM2.5 in China have increased by 17.22 per cent since 1990, in India these have increased by 48 per cent.

Yet another 2017 study published in Journal of Indian Pediatrics (Dr SK Chhabra 2017) shows Indian children growing with smaller lungs. Both boys and girls have lungs that are about 10 per cent smaller when they become adults in India.

Reanalysis of the recently released 2017 state level Global Burden of Disease shows air pollution has moved up the rank as the major killer in nearly all states of India and the diseases directly affected by air pollution like ischemic heart disease and chronic respiratory ailments are the top killers. Relative rank of air pollution as a risk factor has gone up in Arunachal Pradesh, Assam, Bihar, Chattisgarh, Haryana, Himachal Pradesh, Odisha, Rajasthan and Uttar Pradesh. In Delhi, Maharasthra, West Bengal is slightly lowered. But dieses that include cardiovascular diseases, chronic respiratory diseases, and cancers have increased substantially. In Delhi COPD has moved from rank 13 to rank 3; Ischemic heart disease gone up from rank 5 to number 1 etc. This makes the city extremely vulnerable to air pollution.

The data also clearly shows that the age group from 24 to 59 years which is also the most productive life span, the proportion of years lost due to illness and disability from non-communicable diseases exceeds 50% in the 30–34 years group.

Lesson from DelhiEven though Delhi is among the most polluted cities action has taken deeper roots compared to other cities. CSE has evaluated the impact of the emerging action in Delhi on current air quality especially winter air quality.

After a prolonged lull period action started to move since 2015 when the Supreme Court stepped in to issue series of directives in the ongoing public interest litigation on air pollution. Most significant development includes implementation of the Graded Response Action Plan for daily emergency response that was kicked off on October 2017 and the first ever comprehensive action plan that has been adopted officially to mandate time bound short, medium and long term measures to clean up the air of Delhi and NCR with a compliance strategy. This is a very important step forward as according to the

Comprehensive Action Plan Delhi and NCR will have to reduce particulate pollution by at least 74 per cent from the current level of annual average PM2.5 to be able to meet the clean air standards. Such a daunting challenge can be met only with time bound action and strong compliance and deterrence framework. This plan is a comprehensive set of short and long term measures for systemic and transformative changes in industry, power plants, transport and waste sectors. While Graded Response Action Plan helps to respond to daily smog, comprehensive plan will speed up systemic reforms on an ongoing basis. Some of the action which are part of comprehensive action plan including restriction and fiscal charges on truck entry, controlling dieselization with environmental pollution charge on big diesel cars, enforcement on waste burning and construction activities etc are already underway.

As part of the Graded Response Action Plan the measures identified for very poor air quality category will prevail all through the winter which include closure of Badarpur power plant and brick kilns in NCR, diesel generator sets are not allowed in Delhi, action on construction activities and waste burning are being tightened among others. When Delhi experienced smog episode during November 2017 truck entry into Delhi and construction activities were stopped, all stone crushers and hot mix plants were closed and parking charges were increased four times.

CSE analysis of air quality trend shows the following change: While in November 2016 37 per cent o fdays were in emergency category and 20 per cent of days in severe category in 2017 November 24 per cent of days were n emergency and 17 per cent of days in severe category. Similarly, 12 per cent of days in December so far in 2017 are is emergency category as opposed to 17 per cent in 2016. While the levels are still very high the severity and frequency of smog episodes are slightly lower.

It is important to ensure that we do not lose momentum and the action is strengthened to further bend the pollution curve. But Delhi experience also presents an important lesson for other cities of India. All cities need to adopt legally binding comprehensive action plan as well as graded response action plan to meet the clean air targets.

How Delhi action creates opportunity for national action

Action on dirty industrial fuels of Petcoke and Furnace oil CSE and EPCA investigation has exposed extremely high level of sulphur levels in two industrial fuels -- petroleum coke and furnace oil. This ranges from more than 20,000 parts per million (ppm) to 74,000 ppm in contrast to only 50 ppm sulphur in BS-IV transport. Low price and low tax have made these fuels extremely popular.

In 2016, 87 per cent of India’s overseas petcoke came from the US, the world’s largest producer. Its use in US power generation has plummeted due to heavy restrictions. As a result, US refiners and traders are looking to markets with lax regulations. In 2016-17, India’s imports of PetCoke exceeded domestic production, leading to a total consumption of 27-28 million tonnes. Imports of Petcoke alone, has increased to more than 14 times, from 1.02 million tonnes in 2010-11 to 14.37 million tonnes in 2016-17. This represents a Compounded Annual Growth Rate (CAGR) of 45.92 per cent.

Until 2014, China was the biggest buyer of US petcoke. But to battle air pollution it has introduced sulphur restrictions in 2016. To this is added economic downturn and local bans on new power plants. All these have closed supply from the US. Between 2013 and 2014, the trade was cut by half.

Additionally, GST has provided perverse incentives to the use of these fuels. Under GST, these fuels have been put in the in the 18 per cent slab. This input tax under GST is credited back to the industry, making the effective tax rate is 0 per cent. Bu cleaner alternatives such as Natural Gas and Electricity are taxed high – as high as 26% in some states. Import of pet coke is under the Open General Licence (OGL). It is not restricted like other Hazardous substances

Responding to the findings on the dirty industrial fuels submitted by EPCA the Supreme Court issued Directive on October 24, 2017.

Banned use and sale of these fuels in Haryana, Rajasthan and Uttar Pradesh from November 1, 2017, in addition to Delhi, where it has been banned since 1998.

Directed MoEFCC to notify national standards for NOx and SOx for 34 groups of industries. To be implemented by December 31, 2017.

MoEFCC has been fined an amount of Rs 2 lakh for consistent inaction in this regard

Excerpt from Supreme Court Order dated November 17, 2017 –

The Supreme Court also observed, “…We may note that pollution caused by pet coke and furnace oil is not a problem confined only to the NCR region but appears to be a problem faced by almost all the States and Union Territories in the country… we request all the State Governments and Union Territories to consider taking similar measures …”

It is important to note that the MOEFCC has submitted in its affidavit to the Supreme Court stating that it is considering regulating imports of petcoke.

Leapfrog to Bharat Stage VI emissions standards with real world emissions monitoring: The Ministry of Road Transport and Highway has already notified the Bharat VI emissions standards for vehicles from April 2020 onwards. The next level of challenge is to shorten the complete makeover of all vehicle models from BS IV to BS VI in April 2020.

After much push back the vehicle industry has also agreed to adopt real world driving emissions test procedures to ensure that a sample of vehicles is tested for real world emissions on the road. This is very important to ensure life long performance of the advanced emissions control systems like particulate trap and selective catalytic reducing system for NOx reduction in diesel vehicles. This is also needed to prevent cheat devices and prevent episodes like Volkswagen scandal.

Currently, European norms allow diesel vehicles to emit higher particulate matter and NOx compared to petrol vehicles, which is not the case with the US and Japanese norms. For instance at BS IV diesel cars emit three times more NOx and several times higher PM than their petrol counterparts. Only at Euro VI level these norms will be significantly tightened for diesel vehicles. In case of diesel cars the NOx emissions will reduce by 68 per cent, particulate matter by 80 per cent. In case of diesel heavy duty vehicles, the NOx emission will reduce by 89 per cent and particulate matter emissions by 50 per cent. Therefore leapfrogging to BS VI is a significant solution to deal with diesel emissions. The WHO confirmed diesel exhaust as Class 1 human carcinogen. The low tax on diesel fuel had a significant role in shifting the market towards diesel and there was no consideration of air quality and health implications in policy making.

Delhi NCR has taken yet another important step forward. Ministry of Petroleum and Natural Gas responding to the winter smog crisis in Delhi has announced advancement of BSVI fuel in Delhi from April 1, 2018 and in NCR from April 2019. BSVI fuel will bring down sulphur by 5 times from the current BSIV levels as sulfur limit will be 10ppm. This will improve emissions from the existing fleet, even from the older vehicles on road, and reduce wear and tea in existing vehicles. While the MOPNG brings this changeCSE believes that automobile industry must also step up its act and show leadership to fast forward the change, because as per roadmap vehicles will switch to BS VI only from April 2020.

Check on road emissions -- strengthen PUC system: CSE was involved with the survey of PUC centres that was conducted by the EPCA under the direction from the Supreme Court in Delhi and NCR in 2017. This exposed rampant corruption, poor quality testing, use of fake software to issue pass certificates, lack of calibration of equipment, untrained PUC operators among others. Even overall compliance was very poor. Only 23 per cent of vehicles in Delhi turn up for tests. A significant ruling of the Supreme Court in August 2017 that followed based on the recommendations from the EPCA is to link annual vehicle insurance with valid PUC certificate across the country. This needs to be implemented immediately.

Upgrade PUV+C system – integrate on board diagnostic system: Yet another big development that is awaited is the integration of the on-board diagnostic (OBD) system in BSIV vehicles. This is self monitoring system of the vehicles that stores data on a range of performance of vehicles in their memory including emissions performance. These can provide the crucial clue about the problem and the type of repair needed. As part of the PUC system it is important to ensure that all vehicles turning up for the tests have well functioning OBDs and if the malfunctioning light is on. While EPCA has recommended to the Supreme Court its immediate integration with PUC programme for BS IV vehicles, the Union if India has proposed its integration only for transport vehicles and that too only in centralized vehicles testing centres that are being set up and that too from April 2019. This is not acceptable. All four wheeled vehicles BSIV onwards should be brought within the net of OBD testing. These tests cannot be limited to only 10 big centres that are being set up under the Transport Ministry across the country. PUC centres should be equipped to implement OBD.

Need urgent action on vehicles due to rapid motorisation: Stringent action on vehicular pollution and mobility crisis is critical given the current rate of motorization and dieselization in the country. While it has taken 60 years for India to add 100 million vehicles another 100 million have been added only in last 6 years. Similarly, India took 55 years to reach the mark of 10 million cars by 2005. But thereafter it added 20 million – two times more during next 10 years. Both cars and two wheelers have similar growth rate. Close to half of cars are diesel cars.

This is expected to get worse due to growing dependence on personal vehicles and poor state of public transport. This is happening even when the majority is using public transport or are walking and cycling. CSE analysis of Census 2011 data for 16 big cities shows that 30-60 per cent of commuters are still walking and cycling to work places. For instance, 61 per cent in Varanasi, 59 per cent in Kanpur, 55 per cent in Patna, 49 per cent in Kolkata, 45 per cent in Lucknow, 44 per cent in Madurai, 37 per cent in Delhi, 35 per cent in Mumbai, 32 per cent in Pune, 32 per cent each in Chennai and Coimbatore walk or, cycle to work place. Mumbai and Kolkata have the highest share of public transport, walking and cycling share combined – which 88-89 per cent.

Yet state governments are not protecting this ridership. CSE’s new analysis of Delhi bus system has shown massive loss in daily ridership of DTC buses. While public transport share has been generally declining over time, DTC in particular has suffered 35 per cent loss in daily passenger ridership since 2012-13 -- from 47 lakh per day in 2012-13 to 30 lakh per day in 2016. This 35 per cent reduction virtually works out to be a daily loss of about 17 lakh passengers. The city government has not added a new bus in 5 years. Delhi Transport Corporation is currently operating only 3800 buses (discounting fully depreciated buses). Around 1600 buses are being operated under the Cluster Scheme. There is a shortage of 5000-10000 buses based on various estimates and judicial mandates. If not addressed Delhi may not have any bus left in 2025. Based on the age profile of DTC fleet, if no new buses are added, the entire fleet will get phased out by 2025. DTC in 5 years could face a situation of having no buses to run and no staff either.

Cities with high dependence on personal vehicles (cars and two-wheelers) include Jaipur at 45 per cent which is followed by Pune, Hyderabad, Bhopal, Lucknow, Chennai, Indore, Coimbatore, Bengaluru and Delhi. The city with least share of private vehicle usage is Kolkata.

Action on power plan pollution Under Graded Response Action Plan Delhi shuts down the only coal power plant in Badarpur coal during winter. It will be permanently shut from July 2018. This will make Delhi’’s power sector coal free. The Comprehensive Action plan has now sought to augment natural gas supply to power plants in NCR.

However, there is Push back on the new thermal power plant standard. Revised standards for coal based Thermal Power Plants notified in MOEF in December 2015 notified – to be implemented by December 7, 2017. MoEF& CC and Central Electricity Authority, along with the power industry seeking extension of deadline to 2022-24 – more than 7 years delay. Recently MoEF has filed an affidavit in on going air pollution case in the Supreme Court supporting the apprehension of the Ministry of Power that it will take more time to meet the norms, citing the reason that power supply will get affected if all the units are subjected to technology change simultaneously. This is unacceptable as pollution will increase by 50 percent in the next 10 years if implementation of new power standards is delayed.

India's power sector has mostly coal based power plants, highly polluting and inefficient. The weak emissions standards will further aggravated the emissions challenge. The power sector alone contribute 60 per cent of the particulate matter, 45 percent of Sulphur dioxide, 30 percent of nitrogen oxides and 80 percent of mercury emissions of the total emissions from the industrial sector.

Action on construction and wasteFugitive dust from mismanaged construction and demolition (C&D) waste is a serious problem. Supreme Court is monitorin this pollution source. EPCA has developed a check list for inspection of dust control measures in construction site. At the national level the Ministry of Environment and Forests and Climate Change has notified India’s

rules and regulations for construction and demolition waste. Bureau of Indian standards has also finalised specifications for recycled material. This requires mandate for reutilisation of this waste.

Delhi has installed capacity to recycle 50-60 percent of C&D Waste; Ahmedabad about 42 per cent; Bengaluru 37 per cent. Government has mandated use of a minimum Recycled products from construction waste in all future contracts for building works and 10 per cent recycled products for road works.

Similarly, Delhi government has imposed a penalty of Rs. 5000/- for open waste burning and Rs. 50,000/- for not covering the construction sites. But this problem cannot be effectively solved with penalty. Solid waste management rules are Poorly enforced. Cities need to make households and institutions accountable for decentralised management, segeragation, and payment of waste they generate. They need no landfill policy and proper remediation measures to prevent land fill fires as in Gazipur in Delhi or Deonar in Mumbai.

Action on crop burning More than half of this burning happens in 3 states – Punjab, Haryana and Uttar Pradesh. However, incidence of crop residue burning on the rise in Madhya Pradesh, Chhattisgarh, Jharkhand, Odisha, Maharashtra and Telangana, amongst others. Nationally, 40 per cent of all crop residue burning is attributable to Paddy Straw, 22 per cent to Wheat Residue and 20 percent to Sugarcane. Traditionally, most of the paddy stubble was burnt during October–November. India now has a second season of crop residue burning—April–May—from wheat and other Rabi crops. Satellite imaging and remote sensing data show large-scale biomass burning during April and May.

This is increasing because of multiple reasons. Multiple cropping and shortened intervals between crops give a very short window of about 10–15 days during which the field needs to be prepared for the next crop. This does not give enough time for farmers to allow straw to be incorporated in the soil or use other traditional methods of disposal. In Punjab, this interval is further shortened by the rules, which delays the sowing of paddy till after the onset of rains to minimize dependence on groundwater for irrigation. Also increased mechanization of harvesting and the use of mechanized harvesters leave stubble of 10–30 cm in the field, depending on the type of crop, which was not the case earlier with manual harvesting. It is too expensive to hire labour to clear this stubble. Use of expensive labour for stubble extraction is not feasible. Costs are especially high in Punjab and Haryana, where farm sizes are large and use of mechanized harvesters is common. Burning of residues is a cheaper and easier option. The local economy cannot absorb straw any more for roofing of houses etc., as it did earlier. The low commercial and economic value of crop residue, coupled with the high costs of processing, reduces its value for farmers.

Agri-implements, such as the Happy seeders, Choppers and Bailers can process crop residue to prepare it for utilization – either on the field or in industries. However, the cost of agri-implements needed to reduce burning is high. As these implements are used only for two to three weeks a year, farmers do not consider these worth investing. The solution needed would not be subsidy, but encouraging the development of a viable business model which makes such agri-implements easily accessible.

Several solutions are under consideration in the surround states of NCR and Punjab. These include in field solutions including crop residue processing using agricultural implements; subsidy to make these implements accessible to larger number of farmers; co-ownership models for the agri-implements. Ex-situ solutions include utilization of crop-residues fuel in biomass-based power plants and prioritsiaion of Biomass based Powerplants; production of biofuels and fertilizers and other uses. This will also require R&D and crop diversification and support to research projects that can work towards reducing crop residue generation. This will have to be supported by uniform decentralized mechanism for the collection, storage and commercial sale of crop residue. These solutions need scale, business model and policy support.

Need legal compliance frame work to meet clean air targetThe Air Act 1981, provides for and empowers the Central Pollution Control Board (CPCB) and the SPCBs to create programmes to control emission levels, prescribe regulations for industries and related entities engaged in activities potentially hazardous to the environment. Section 16 of the Air Act sets a mandate on CPCB to maintain the desired air quality in the country and empowers it to take all necessary measures to this end. The CPCB under the Air Act has the power to issue guidelines and promulgate programmes aimed at monitoring emission levels in India. Legal action will have to be further strengthened to ensure compliance to meet clean air target.

It is important to recognise action – small as they may seem now – to change the trajectory. Need strong advocacy capacity for public messaging to deal with denial and influence the politics of change. The country needs big answers.